NOVEMBER 29, 2015

**U. S.	Department	of	T**  **ransportation,	Docket	Operations** We st	Building	Ground Floor ,	Room	w12
- 140

Dear Administrator , Pursuant	to	Section	333	of	the	F AA	Modernization	and	Reform	Act	of	2012	(the	“Reform	Act”)	and	14 C.F .R.	P art	11,	Eyebot	Aerial	Solutions	(“Eyebot”),a	multi
- service	U AS	Service	company ,	seeks	an exemption	from	the	F ederal	A viation	Regulations	(“F

ARs”)	listed	below	to	allow	commercial	operation	of its	U ASs	so	long	as	such	operations	are	conducted	within	an	under	the	conditions	outlined	herein	or	as may	be	established	by	the	F AA	as	required	by	Section	333. The	requeste d	exemption	would	permit	commercial	operation	of	Eyebots	U AS,	which	are,	multi	rotor aircraft,	weighing	less	than	55	lbs.	including	cargo	and	performs	precision	aerial	inspections, photogrammetry

,	mapping	and	surveys	that	consist	of	still	photographs	or	vi deo	taken	by	an	onboard camera.	Applications	for	these	U AS	devices	and	associated	data	processing	functions	include	mining	and professional	surveying	as	well	as	inspections	of	difficult	to	reach	equipment	or	structures	including bridges,	cell	towers,	flare stacks	etc.	Use	of	the	U AS	for	aerial	surveys	and	inspections	reduces	the	need	to operate	conventional	aircraft	or	other	equipment	for	the	same	purpose	and	provides	very	high	quality imagery	at	a	fraction	of	the	cost	of	surveys	and	inspections	using	con ve ntional	means.	Likewise, inspections	of	structures	can	be	safely	performed	without	endangering	the	inspector	or	inhibiting	local industrial	or	public	operations	with	ladders,	lifts	or	other	equipment.	These	savings	result	in	enhanced efficiency	and	product iv ity	for	the	affected	acti vities,	as	well	as	environmental	benefits	and	potential savings	in	both	cost	and	hazards	to	the	public. This	request	would	also	permit	Eyebot to conduct	aerial	photography	for	the	use	in	public	periodicals, motion	picture	and	te levision	industry	for	con trolled	and	closed	set	filming.		This	request	would	permit the	operation	of	small	U AS	under	controlled	conditions	in	airspace	that	is	1)	limited	2)	predetermined	3) controlled	as	to	access	and	4)	would	provide	safety	enhancements	t o	the	alread y	safe	operations	in	the film	and	television	industry	presently	using	con ventional	aircraft.		Approval	of	this	exemption	would thereby	enhance	safety	and	limit	en vironmental	impact	significantly
. Eye bot	Aerial	Solutions 2096	Spooky	Hollow	Rd jakelydick@gmail.com www .eye - bot.comPa ge 2

The	name	and	address	of	the	applicant	is :

**Eyeb ot	Aerial	Solutions**  **Attn:	Jake	L**

**yd ick**  **Phone:	724 -**  **816 -**  **2619 Email:**  **jakelydick@gmail.com Address:	2096	Spooky	Hollo**  **w	Rd,	New	Kensington,	P A	15068** 
Regulations	from	which	the	exemption	is	requested: 14	CFR	P art	21 14	C.F .R.	45.23(b) 14	CFR	61.113	(a)	&	(b) 14	C.F .R.	91.7	(a) 14	CFR	91.9	(b)	(2) 14	C.F .R.	91.103 14	C.F .R.	91.109 14	C.F .	R.	91.119 14	C.F .R.	91.121 14	CFR	91.151	(a) 14	CFR	91.203	(a)	&	(b) 14	CFR	91.405	(a) 14	CFR	407	(a)	(1) 14	CFR	409	(a)	(2) 14	CFR 417	(a)	&	(b) Section	333(a)	through	(c)	of	the	Reform	Act.	This	law	directs	the	Secretary	of	T ransportation	to	consider	whether certain	unmanned	aircraft	systems	may	operate	safely	in	the	national	airspace	system	(NAS)	before	completion	of	the rulemaking required	under	Section	332	of	the	Reform	Act.	In	making	this	determination,	the	Secretary	is	required	toPa ge 3

determine	which	types	of	U ASs	do	not	create	a	hazard	to	users	of	the	NAS	or	the	public	or	pose	a	threat	to	national security	in	light	of	the	following:

• The	U AS’s	size,	weight,	speed,	and	operational	capability;

• Operation	of	the	U AS	in	close	proximity	to	airports	and	populated	areas;	and

• Operation	of	the	U AS	within	visual	line	of	sight	of	the	operator
. Reform	Act	§	333	(a).	If	the	Secretary	determin es	that	such	vehicles	“may	operate	safely	in	the	national	airspace system,	the	Secretary	shall	establish	requirements	for	the	safe	operation	of	such	aircraft	in	the	national	airspace system. ”	Id.	§333(c)	(emphasis	added). The	Federal	A

viation	Act	expressly grants	the	F AA	the	authority	to	issue	exemptions.	This	statutory	authority	by	its terms	includes	exempting	civil	aircraft,	as	the	term	is	defined	under	§40101	of	the	Act,	that	includes	U ASs,	from	the requirement	that	all	ci vil	aircraft	must	have	a	current airworthiness	certificate. Eye bot interprets	this	provision	to	place	the	duty	on	the	Administrator	to	not	only	process	applications	for	exemptions under	section	333,	but	for	the	Administrator	to	craft	conditions	for	the	safe	operation	of	the	U AS,	if	it	sh ould	be determined	that	the	conditions	set	forth	herein	do	not	fulfill	the	statutory	requirements	for	approva l. The	Administrator	may	grant	an	exemption	from	a	requirement	of	a	regulation	prescribed	under	subsection	(a)	or	(b) of	this	section	or	an y	sectio ns	44702
- 44716	of	this	title	if	the	Administrator	finds	the	exemption	in	the	public	interest. 49	U.S.C.	§44701(f )	See	also	49	USC	§44711(a);	49	USC	§44704;	14	CFR	§91.203	(a)	(1). Eye bots UA S	is	a re	rotorcraft ,	weighing	less	than	55	lbs.	including	payload. They	operate under	normal	conditions	at	a sp eed	of	no	more	than	87	knots	and	have the	capability	to	hover ,	and	move	in	the	vertical	and	hor izontal	plane simultaneously

.	They will	operate	only	in	line	of	sight	of	the	pilot	and	will	operate	only	within	the project	area.	Such operations	will	insure	that	the	U AS	will	not	create	a	hazard	to	users	of	the	national	airspace	system	or	the	public. Gi ve n	the	small	size	of	the	UAS	involved	and	the	restricted	en vironment	within	whic h	it	will	operate,	Eyebot falls squar ely	within	that	zone	of	safety	(an	equi va lent	level	of	safety)	in	which	Congress	en visioned	the	F AA	must,	by exemption,	allow	commercial	operations	of	U ASs	to	commence	immediately .	Also	due	to	the	size	of	the	U AS	and	the restricted	areas	in	which	the	relev ant	U AS	will	operate,	approval	of	the	application	presents	no	national	security	issue. Gi ve n	the	clear	direction	in	Section	333	of	the	Reform	Act,	the	authority	contained	in	the	F ederal	A viation	Act,	as amended;	the	strong	equi va lent	lev el	of	safety	surrou nding	the	proposed	operations,	and	the	significant	public	benefit, including	enhanced	safety ,	reduction	in	en vironmental	impacts,	including	reduced	emissions	associated	with	allowing UA Ss	for inspection	and	survey , volumetric	mapping,	thermal	imaging,	real estate	photography	and movie	and tel evision	operations, the	grant	of	the	requested	ex emptions	is	in	the	public	interest.	Accord ingly ,	E yebot respectfully requests	that	the	F

AA	grant	the	requested	ex emption	without	delay
. Aircraft	and	equi va lent	Level	of Safety Eye bot proposes	the	exemption	requested	herein	apply	to	ci vil	aircraft	that	have	the	characteristics	and	that	operate with	the	limitations	listed	herein.	These	limitations	provide	for	at	least	an	equivalent	or	even	higher	level	of	safety	to operatio ns	under	the	current	regulatory	structure	because	the	proposed	operations	represent	a	safety	enhancement to	the	already	safe	photography	and	surveying	operations	conducted	with	conventional	aircraft.Pa ge 4

These	limitations	and	c onditions	to	which	Eyebot agrees	to	be	bound	when	conducting	commercial	operations	under an	F AA	issued	exemption	include: 1
. The	U AS	will	wei gh	less	than	55 lbs. 2
. Flights	will	be	operated	within	line	of	sight	of	a	pilot	and/or	observer
. 3
. Maximum	total	flight	time	for	each	oper ational	flight	will	be no	longer	than	3 0	minutes.	Flights	will	be terminated	at	25%	battery	power	reserve	should	that	occur	prior	to the	30	minute	limit. 4
. Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	AGL. 5
. Minimum	crew	for	each operation	will	consist	of	the	U AS	Pilot	and	a	Visual	Observer
. 6
. UA S	pilot	will	be	a	skilled	U AS	operator	experienced	in	the	type	of	U AS	flown. 7
. UA S	Pilot	will	be	Pilot	in	Command	(PIC).	If	a	pilot	certificate	holder	other	than	the	UASPilot,	who	posses s	the necessary	PIC	qualifications,	is	also	present	that	person	can	also	be	designated	as	PIC. 8
. The	U AS	will	only	operate	within	a	confined	Project	Area. 9
. A	briefing	will	be	conducted	in	regard	to	the	planned	U AS	operations	prior	to	aerial acti vities. All	personnel who	will	be	performing	duties	within	the	boundaries	of	the	safety	perimeter	will	be	made	aw are	of	the	U AS filght(s). 10
. The	operator	will	obtain	the	consent	of	all	persons	involved	in	the	project	and	ensure	that only	consenting persons	will be	allowed	within	100	feet	of	the	flight	operation. 11
. Pilot	and	observer	will	have	been	trained	in	operation	of	U AS	generally	and	received	up to - date	information on	the	particular	U AS	to	be	operated. 12
. Observer	and	pilot	will	at	all	times	be	able	to	co mmunicate	by	voice	and/or	visuals. 13
. Wr itten	and/or	oral	permission	from	the	relevant	property	holders	will	be	obtained. 14
. All	required	permissions	and	permits	will	be	obtained	from	territorial,	state,	county	or	city jurisdictions, including	local	law enforcement,	fire,	or	other	appropriate	governmental	agencies. 15
. If	the	U AS	loses	communications	or	loses	its	GPS	signal,	the	U AS	will	have	capability	to return	to	a	pre determined	location	within	the	Security	P erimeter	and	land. 16
. The	U AS	will	have	th e	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles	or emergencies. 17
. In	the	case	of	closed	set	operations	Eyebot	mandates	a	minimum	25	hours	PIC	logged	in	the	aircraft	to perform	the	operations,	with	no less	than	50	takeoff/landings 18
. A	“F light	Profile	Briefing”	will	be	conductor	prior	to	each	light.		All	production	personel	performing	duties within	the	boundaries	of	the	safety	perimeter	shall	be	a	part	of	the	briefing.Pa ge 5

19
. Eye bot	shall	file	a	F AA	form	7711
- 1,	or	its	equi va lent,	as	modified in	light	of	the	requested	exemption,	with	the appropriate	FSDO
. 20
. Eye bot	will	submit	a	written	Plan	of	Acti vities	to	the	FSDO	three	days	prior	to	filming	operations
Description	of	Specific	Regulations: 14	CFR	P art	21,	Subpart	H:	Airworthiness	Certifica tes	14	C.F .R.	§91.203(a)(1) Subpart	H,	entitled	Airworthiness	Certificates,	establishes	the	procedural	requirements	for	the	issuance	of airworthiness	certificates	as	required	by	F AR	§91.203	(a)	(1).	Gi ven	the	size	and	limited	operating	area	associated with the	aircraft	to be	utilized	by	Eyebot ,	an	exemption	from	P art	21	Subpart	H	meets	the	requirements	of	an equi va lent	level	of	safety	under	P art	11	and	Section	333	of	the	Reform	Act.	The	F ederal	A viation	Act	(49	U.S.C.§44701 (0)	and	Section	333	of	the	Reform Act	both	authorize	the	F AA	to	ex empt	aircraft	from	the	requirement	for	an airworthiness	certificate,	upon	consideration	of	the	size,	weight,	speed,	operational	capability ,	and	proximity	to airports	and	populated	areas	of	the	particular	U AS.	Our	small	U AS will	be	operated	at	low	speed	in	a	controlled en vironment	at	least	fi ve	miles	from	an	airport.	An	analysis	of	these	criteria	demonstrates	that	the	U AS	operated without	an	airworthiness	certificate,	in	the	restricted	environment	and	under	the	conditions	pro posed	will	be	at	le ast safe,	or	safer

,	than	a	con ventional	aircraft	(fixed	wing	or	helicopter)	operating	with	an	airworthiness	certificate without	the	restrictions	and	conditions	proposed. The	U AS	to	be	op erated	hereunder	is	less	than	55 lbs.	fully	loaded, carries	neither	a	pilot	nor	passenger ,	carries	no explosive	materials	or	flammable	liquid	fuels,	and	operates	ex clusi vely	within	a	secured	area.	Like	other	ci vil	aircraft, operations	under	this	exemption	will	be	tightly	controlled	and	monitored	by	the	ope rator ,	pursuant	to	the	Manual's requirements,	and	under	the	requirements	and	in	compliance	with	local	public	safety	requirements,	to	provide security	for	the	area	of	operation	as	is	currently	done	on	acti ve construction	sites.	The	F AA	will	have	advance	not ice	of all	operations. These	safety	enhancements,	which	alread y	apply	to	ci vil	aircraft	operated	in	connection	with	construction	sites, provide	a	greater	degree	of	safety	to	the	public	and	property	owners	than	con ventional	operations	conducted	with airwort hiness	certificates	issued	under	14	C.F .R.	P art	21,	Subpart	H.	Lastly ,	application	of	these	same	criteria demonstrates	that	there	is	no	credible	threat	to	national	security	posed	by	the	U AS,	due	to	its	size,	speed	of	operation, location	of	operation,	lack of	explosi ve	materials	or	flammable	liquid	fuels,	and	ability	to	carry	an	external	load	no greater	than	two	lbs. 14	C.F .R.	45.23(b):	Marking	of	the	Aircraft This	regulation	requires	certain	experimental,	provisionally	certificated	aircraft,	or	light	sport category	aircraft	to	be marked	with	letters	between	2	inches	and	6	inches	high	"limited, "	“restricted, "	"light
- sport, "	"experimental, "	or "provisional, "	near	each	entrance	to	a	cabin,	cockpit,	or	pilot	station. Eve n	though	the	U AS	will	have	no	airworthines s	certificate,	an	exemption	may	be	needed	as	the	U AS	will	have	no entra nce	to	the	cabin,	cockpit	or	pilot	station	on	which	the	word	Experimental"	can	be	placed.	Given	the	size	of	the UA S,	two
- inch	lettering	will	be	impossible.	The	word	"Experimental"	will be	placed	on	the	fuselage	in	compliance	with §45.29	(f ).Pa ge 6

The	equi va lent	level	of	safety	will	be	provided	by	having	the	U AS	marked	on	its	fuselage	as	required	by	§45.29	(f ) where	the	pilot,	observer	and	others	working	with	the	UAS	will	see	the	identificatio n	of	the	U AS	as	"Experimental. " The	F AA	has	issued	the	following	exemptions	to	this	regulation:	Exemptions	Nos.	10700,	8738,	10167	and	10167A. 14	CFR	61.113	(a)	&	(b):	Private	pilot	pri vileges	and	limitations:	Pilot	in	command Sections	61.113	(a)	&	(b)	lim it	pri va te	pilots	to	non
- commercial	operations.	Unlike	a	con ventional	aircraft	that	carries the	pilot	and	passengers,	the	U AS	is	remotely	controlled	with	no	living	thing	or	cargo	on	board.	The	area	of	operation is	controlled	and	restricted,	a nd	all	Docket Management	S ystem flights	are	planned	and	coordinated	in	ad va nce.	The risks	associated	with	the	operation	of	the	U AS	are	so	diminished	from	the	level	of	risk	associated	with	commercial operations	contemplated	by	P art	61	when	drafted,	that	allowing	operatio ns	of	the	U AS	as	requested	with	a	pilot	who	is an	experienced	U AS	operator	exceeds	the	present	level	of	safety	achieved	by	14	C.F .R.	§61.113	(a)	&	(b). 14	C.F .R.	91.7	(a):	Ci vil	aircraft	airworthiness The	regulation	requires	that	no	person	may	operate	a ci vil	aircraft	unless	it	is	in	airworthy	condition.	As	there	will	be no	airworthiness	certificate	issued	for	the	aircraft,	should	this	exemption	be	granted,	no	F AA	regulatory	standard	will exist	for	determining	airworthiness.	Gi ven	the	size	of	the	aircraft and	the	requirements	contained	in	the	Manual	for maintenance	and	use	of	safety	checklists	prior	to	each	flight,	an	equi va lent	level	of	safety	will	be	provided. 14	CFR	91.9	(b)(2):	Ci vil	aircraft	flight	manual,	marking,	and	placard	requirements The	U AS,	gi ve n	its	size	and	configuration	has	no	ability	or	place	to	carry	such	a	flight	manual	on	the	aircraft,	not	only because	there	is	no	pilot	on	board,	but	because	there	is	no	room	or	capacity	to	carry	such	an	item	on	the	aircraft. The	equi va lent	level	of	safet y	will	be	maintained	by	keeping	the	flight	manual	at	the	ground	control	point	where	the pilot	flying	the	U AS	will	have	immediate	access	to	it.	The	F AA	has	issued	the	following	exemptions	to	this	regulation: Ex emption	Nos.	8607,	8737,	8738,	9299,	9299A,	956 5,	9565B,	10167,	10167A,	10602,	32827,	and	10700. 14	C.F .R.	91.103:	Preflight	Action This	regulation	requires	each	pilot	in	command	take	certain	actions	before	flight	to	ensure	the	safety	of	flight.	An exemption	is	needed	from	this	requirement	as	the	pilot will	take	separate	preflight	actions,	including	checking	for weather	conditions,	checking	flight	battery	requirements,	checking	takeoff	and	landing	distances,	and	all	other	actions in	the	Preflight	Checklist	in	the	U AS	Manual.	These	actions	will	provide	a n	equi va lent	level	of	safety
. 14	C.F .R.	91.109:	Flight	Instruction Section	91.103	provides	that	no	person	may	operate	a	ci vil	aircraft	(ex cept	a	manned	free	balloon)	that	is	being	used for	flight	instruction	unless	that	aircraft	has	fully	functioning	dual controls. By	design,	U ASs	and	remotely	piloted	aircraft	do	not	have	fully	functional	dual	controls.	Flight	control	is	accomplished through	the	use	of	a	control	box	that	communicates	with	the	aircraft	via	radio	communications.	The	F AA	has prev iously	approve d	exemptions	for	aircraft	without fully functional	dual	controls.	See	Exemption	Nos.5778K	& 9862A.	The	equi va lent	level	of	safety	provided	by	the	fact	that	neither	a	pilot	nor	passengers	will	be	carried	in	the aircraft,	the	ability	to	control	the	U AS	via	r adio	signals	from	the	controller ,	and	by	the	size	and	speed	of	the	aircraft.Pa ge 7

14	C.F .	R.	91.119:	Minimum	Safe	Altitudes Section	91.119	establishes	safe	altitudes	for	operation	of	ci vil	aircraft.	Section	91.119	(d)	allows	helicopters	to	be operated	at	less than	the	minimums	prescribed,	provided	the	person	operating	the	helicopter	complies	with	an y	route or	altitudes	prescribed	for	helicopters	by	the	F AA.	This	ex emption	is	for	a	multirotor	craft	that	flies	similarly	to	a helicopter

,	with	vertical	take	off	and ve rtical	landing,	which	will	typically	operate	at	altitudes	of	200	AGL	so	an exemption	may	be	needed	to	allow	such	operations.	The	U AS	will	never	operate	at	an	altitude	higher	than	400	AGL and	will	be	in	a	restricted	area,	where	buildings	and	people	will not	be	exposed	to	operations	without	their	pre
obtained	consent.	The	equi valent	level	of	safety	will	be	achieved	gi ven	the	size,	weight,	speed	of	the	U AS	as	well	as	the location	where	it	is	operated.	No	flight	will	be	taken	without	the	permission	of	the	pr operty	owner	or	local	officials. Because	of	the	ad va nce	notice	to	the	property	owner	and	an y	onsite	personnel	all	affected	indi viduals	will	be	aw are	of the	planned	flight	operations.	Compared	to	flight	operations	with	aircraft	or	rotorcraft	weighing	far	mo re	than	the maximum	30	lbs.	proposed	herein	and	carrying	flammable	fuel,	an y	risk	associated	with	our	operations	is	far	less	than those	presently	presented	with	helicopters	and	other	conventional	aircraft	operating	at	or	below	500	AGL	in	the industry .	In	a ddition,	the	low
- altitude	operations	of	the	UAS	will	ensure	separation	between	these	small	U AS operations	and	the	operations	of	conventional	aircraft	that	must	comply	with	Section	91.119. 14	C.F .R.	91.121:	Altimeter	Settings This	regulation	requires	each	p erson	operating	an	aircraft	to	maintain	cruising	altitude	by	reference	to	an	altimeter that	is	set	"...to	the	elevation	of	the	departure	airport	or	an	appropriate	altimeter	setting	available	before	departure. " As	the	U AS	may	not	have	a	barometric	altimeter ,	but	instead	a	GPS	altitude	read	out,	an	ex emption	may	be	needed.	An equi va lent	level	of	safety	will	be	achieved	by	the	operator ,	pursuant	to	the	U AS	Manual	and	Safety	Check	list, confirming	the	altitude	of	the	launch	site	shown	on	the	GPS	altitude	indica to r	before	flight. 14	CFR	91.151	(a):	Fuel	requirements	for	flight	in	VFR	conditions Section	91.151	(a)	outlines	fuel	requirements	for	beginning	a	flight	in	VFR	conditions.	Our	U AS	is	limited	to	operations in	sterile	and	controlled	en vironments	and	has	a	l imited	range	and	flight	time	which	require	an	exemption	from	14 CFR	91.151(a). The	battery	powering	the	UAS	provides	approximately	20	minutes	of	powered	flight.	This	does	not	meet	the	30	minute reserve requirement	in	14	CFR	§91.151. Eye bot believes	that	an exemption	from	14	CFR	§91.151(a)	falls	within	the	scope	of	prior	ex emptions.	See	Ex emption 10673	(allowing	Lockheed	Martin	Corporation	to	operate	without	compliance	with	F AR	91.151	(a)).	Operating	the small	U AS,	in	a	tightly	controlled	area	where	only	peo ple	and	property	owners	or	official	representati ves	who	have signed	w ai vers	will	be	allowed,	with	less	than	30	minutes	of	reserve	fuel,	does	not	engender	the	type	of	risks	that Section	91.151(a)	w as	intended	to	alleviate	given	the	size	and	speed	of	the	sma ll	U AS.	An	equi va lent	level	of	safety	can be	achieved	by	limiting	flights	to	15	minutes,	or	enough	battery	reserve	to	ensure	that	the	U AS	lands	at	the	ground station	with	at	least	20%	of	battery	power	(as	determined	by	the	onboard	monitoring	system	and	the pilot), whichever	happens	first.	This	restriction	would	be	more	than	adequate	to	return	the	U AS	to	its	planned	landing	zone from	an yw here	in	its	limited	operating	area.	Similar	ex emptions	have	been	granted	to	other	operations,	including Ex emptions	2689F

, 5745,	10673,	and	10808. 14	CFR	91.203	(a)	&	(b):	Carrying	ci vil	aircraft	certification	and	registrationPa ge 8

The	regulation	provides	in	part: (a) Ex cept	as	provided	in	§	91.715,	no	person	may	operate	a	ci vil	aircraft	unless	it	has	within	it	the	following: (1)	A n	appropriate	and	current	airworthiness	certificate... (b) No	person	may	operate	a	ci vil	aircraft	unless	the	airworthiness	certificate	required	by	paragraph	(a)	of	this section	or	a	special	flight	authorization	issued	under	§91.715	is	displayed	at	the	cabin or	cockpit	entrance	so	that	it	is legible	to	passengers	or	crew
. The	U AS	ful ly	loaded	weighs	no	more	than	55 lbs	and	is	operated	without	an	onboard	pilot.	Therefore	there	is	no ability	or	place	to	carry	certification	and	registration	documents	or	to	displa y	them	on	the	U AS. An	equi va lent	level	of	safety	will	be	achieved	by	keeping	these	documents	at	the	ground	flight	control	point	where	the pilot	flying	the	U AS	will	have	immediate	access	to	them,	to	the	extent	they	are	applicable	to	the	U AS.	The	F AA	has iss ued	numerous	exemptions	to	this	regulation.	A	representati ve	sample	of	other	ex ceptions	includes	Ex emption	Nos. 9565,	9665,	9789,	9789A,	9797,	9797A,	9816A,	and	10700. 14	CFR	91.405	(a);	407	(a)(1);	409	(a)(2);	417	(a)	&	(b):	Maintenance	inspections These regulations	require	that	an	aircraft	operator	or	owner	"shall	have	that	aircraft	inspected	as	prescribed	in subpart	E	of	this	part	and	shall	between	required	inspections,	ex cept	as	provided	in	paragraph	(c)	of	this	section,	have discrepancies	repaired	as	p rescribed	in	part	43	of	this	chapter ..., "	and	others	shall	inspect	or	maintain	the	aircr aft	in compliance	with	P art	43. Gi ve n	these	sections	and	P art	43	apply	only	to	aircraft	with	an	airworthiness	certificate	these	sections will	not	apply	to Eye bot .	Maint enance	will	be	accomplished	by	the	operator	pursuant	to	the	flight	manual	and	operating	handbook.	An equi va lent	level	of	safety	will	be	achieved	because	these	small	U ASs	are	very	limited	in	size	and	will	carry	a	small payload	and	operate	only	in	restricted areas	for	limited	periods	of	time.	If	mechanical	issues	arise	the	U AS	can	land immediately	and	will	be	operating	from	no	higher	than	400	feet	AGL.	The	operator	will	ensure	that	the	U AS	is	in working	order	prior	to	initiating	flight,	perform	required	maint enance,	and	keep	a	log	of	an y	maintenance	performed. Moreover

,	the	operator	is	the	person	most	familiar	with	the	aircraft	and	best	suited	to	maintain	the	aircraft	in	an airworthy	condition	to	provide	the	equi va lent	level	of	safety
.
******** Pursuant	to	14 C.F

.R.	P art	11,	the	following	summary	is	provided	for	publication	in	the	F ederal	Register ,	should	it	be determined	that	publication	is	needed: Eye bot seeks	an	ex emption	from	the	following	rules:14	C.F .R.	§21,	subpart	H; 14	C.F .R	45.23(b);14	C.F

.R.	§§	61.11 3(	a)	&	(b);91.7	(a);	91.9	(b)	(2);91.103(b);91.109;	91.119;	91.121; 91.151(a);91.203(a)	and	(b);	91.405	(a);	91.407	(a)	(1);	91.409	(a)	(2);	91.409	(a)	(2)	and	91.417	(a)	&	(b)	to	operate commercial ly	a	small	unmanned	vehicle	(55l bs	or	less)	in	constructi on,	mining,	surveying,	or	inspection	operations. Approval	of	exemptions	allowing	comme rcial	operations	of	U ASs	in volumetric	mapping,	thermal	imagin g,	real	estate photography	and movie	and	television	operations construction,	mining,	surveying,	or	inspection	industry	enhances safety	while	reducing	risk.	Manned	aircraft	monitoring	and	surveying	creates	a	greater	risk	because	the	craft	are	muchPa ge 9

larger ,	have	combustible	fuel,	and	carry	an	onboard	human	pilot.	In	cont ra st,	a	U AS	weighing	fewer	than	55 lbs.	and powered	by	batteries	eliminates	virtually	all	of	that	risk	gi ven	the	reduced	mass	and	lack	of	combustible	fuel	carried on	board.	The	U AS	will	carry	no	passengers	or	crew	and,	therefore,	will	not	expose	them	to	th e	risks	associated	with manned	aircraft	flights. The	operation	of	sm all	U ASs,	weighting	less	than	55 lbs.,	conducted	in	the	strict	conditions	outlined	above,	will	provide an	equivalent	level	of	safety	supporting	the	grant	of	the	ex emptions	requested	herein ,	i ncluding	exempting	Eyebot from	the	requirements	of	P art	21	and	allowing	commercial	operations.	These	lightweight	aircraft	operate	at	slow speeds,	close	to	the	ground,	and	in	a	sterile	en vironment	and,	as	a	result,	are	far	safer	than	con ventional	operati ons conducted	with	helicopters	operating	in	close	prox imity	to	the	ground	and	people. Privacy All	flights	will	occur	over	private	or	controlled	access	property	with	the	property	owner's	prior	consent	and knowledge.	Images	taken	will	be	of	indi viduals	who	h ave	also	consented	to	being	filmed	or	otherwise	have	agreed	to be	in	the	area	where	aerial	photography	will	take	place. Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Reform	Act	of	2012
-- size,	weight,	speed,	operating capabilities,	proximity	t o	airports	and	populated	areas	and	operation	within	visual	line	of	sight	and	national	security

— provide	more	than	adequate	justification	for	the	grant	of	the	requested	exemptions	allowing	commercial	operation of	Eyebots UA Ss	in	construction	industry	pursu ant	to	the	U AS	Manual. Specific	Exam ples	of	P otential	U AS	use	by	Eyebot : Eye bot	currently	has	available	a	Freefly	S ystems	Alta,	DJI	Inspire	1 ,		and DJI	Phantom	3 to use	if/when	perm ission	is granted. All	of	the	previous	equipment	has	been	listed	on	several granted	section	333	exemptions.(CopelandRED	LLC Ex emption	#	12103)	(Aerial	Enterprises,	Inc,	Ex emption	#	12432) Purchase	of	similar	models may	be	pursued	at	a later	date. Use	of	these tool s would	allow	Eyebot to: ·	Inspect	existing	inaccessible	or	difficul t	to	access	structures	such	as	tops	of	ri ver	cells,	sides	of	bridges,	industrial rooftops,	and	smoke	stacks.	This	would	save	time	and	money	and	public	incon veniences	by	negating	the	need	to mobilize	large	lift	equipment	or	close	roads	during	bridge	or	publ ic	building	inspections.

· Develop	3D	models	from	imagery	collected	during	flight.	Using	softw are	to	turn	photographs	into	scalable	3D models	minimizes	the	need	for	tape	measures	and	other	‘hands	on ’	surveying	tools	which	can	inhibit	industrial	and public operations	as	well	as	be	a	safety	issue	to	the	employee	and	public.

· Develop	land	surveys	quickly	and	inexpensi vely	compared	to	conventional	methods.	Aerial	surveys	can	be conducted	on	small	areas	with	the	U AS	negating	the	need	for	large	con ventional	ai rcraft	and	other	conventional surveying	devices	which	may	inhibit	industrial	or	public	operations.

· Enhanced	public	aw areness.	Eyebot’s	services	include public	places	such	as	bridges,	biking/hiking	trails, landfill	closures,	etc.	The	ability	to	use	up	to date	aerial	photography	will	enable	the	client	and	the	public	to	better understand	the	project.Pa ge 10

· Real	Estate	inspections,	Photography	and	Closed	set	filming.		Eyebot	intends	to	use	small	U AS	under	55	lbs where	conventional	aircraft	were	previously	emplo ye d	to	perform	the	same	operation.		Small	U AS	do	not	risk	pilot	and crew	and	greatly	reduce	en vironmental	impact	therefor	adding	significant	public	benefit.
Eye bot	would	ask	the	Administrator	to	consider	all	previously	aw arded	exemptions	as	supporting	arg uments	to	this exemption	request
Should	the	administrator	require	an y	additional	information	or	clarification	please	contact	me	directly
Jake	L ydick Eye bot	Aerial	Solutions 2096	Spooky	Hollow	Rd New	Kensington,	P

A	15068 TEL	724.816.2619 jakelydick@gmail. com